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5. Petitioner has obtained a document, supplied
by Respondent showing the word Document on
it, although mis-spelled, at or near the time
Petitioner claims documents were supplied to
the Fresno service center.
6. Petitioner requested depositions to be
authorized by this Court to examine the word
document, and or the absence of it and the
use and recollection of statements made by
IRS reps to Petitioner’s Counsel. This
request was denied. Petitioner instead was
forced on relying on Respondent obtaining
statements regarding this mis-spelled word in
Petitioner’s transcript. [Reproduced
literally.]
We have searched in vain for “a document, supplied by
Respondent showing the word Document on it, although mis-
spelled”. Based on notes of telephone conferences the Court held
with counsel for the parties, we surmise that petitioner intends
to refer to stipulated Exhibit 3-J, “a transcript of petitioner’s
2002 tax account, entitled ‘IMF MCC Transcript - Specific’.”
Based on these notes, we further surmise that the item petitioner
intends to refer to is the following:
290 07282003 0.00 200329 93254-999-05099-3
HC3 ARC-002-071 INTD PC
CORRESPONDDT- CREDIT DT-
REFUND STATUTE CONTROL DT-
AMD CLMS DT- CIS MF IND-O
CSED-
In his answering legal memorandum petitioner asserts as
follows:
Petitioner has submitted documentation indicating he
has submitted proof orally as well as in writing.
Respondent has claimed that the misspelled word
document on Petitioner’s file has no basis, to the fact
Petitioner submitted documents, while not showing
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